Due diligence checklist, United States
NYDFS Part 500: what to ask a vendor
23 NYCRR Part 500, Cybersecurity Requirements for Financial Services Companies. NYDFS. A written policy for third-party providers: due diligence, minimum controls and periodic assessment.
What it is
A written policy for third-party providers: due diligence, minimum controls and periodic assessment.
Who it applies to
Applies to every financial institution in the United States.
What to ask a vendor, and the evidence to request
| # | Ask the vendor for | Evidence to request |
|---|---|---|
| 1 | Multi-factor authentication, encryption and access controls that meet Part 500 | A description of the security controls, the most recent control testing or penetration test summary, and the policies for vulnerability, change and access management. |
| 2 | Notice of cybersecurity events in time for the institution's 72-hour report to the Department | The incident notification clause and procedure: what counts as an incident, who is told, within what time, and a record of a past notification if one exists. |
In every case
- A named contact at the vendor responsible for this regime, and how the vendor tracks changes to it.
- Which named customers the vendor already serves under this regime, as references you may call.
This checklist is a starting point for a procurement team, not legal advice. Read it with the regulator's own page, your institution's policies and your legal and risk teams; the regime may have changed since the date on this document.
Next
- Every checklist, by country
- What a market scan is and how to run one
- Have Vederca run the procurement: the regime goes into the register as a must-have